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Establishing a Water Resource Issue Management Program 41 ations group performs that deal primarily with accessing the impacts of airport projects on flight safety and changing the information in the pilot manuals regarding airport-specific changes resulting from projects. Station Operational Certification and Compliance Management--manages the airline's FAA compliance issues at the stations and will assess project impacts on that compliance. 3. Outside Consultants: Development Project Planners--work with airport operators to assess capacity require- ments, lead assessment of development needs and alternatives, and prepare planning doc- uments such as Master Plans. Development Project Engineers and Architects--prepare conceptual and detailed design of the development project features. Work with airport on integrating project design with existing airport operations. Water Resource Issue Engineers and Scientists--understand details of environmental regulations, provide guidance on coordinating with regulatory agencies on permitting and compliance for individual water resource issues, consider mitigation options, and prepare conceptual and detailed design of controls and mitigation measures. NEPA Consultants--assist the FAA and airport planners with project planning and scope; lead the preparation of Environmental Impact Statements (EISs), Environmental Assess- ments (EAs), or Categorical Exclusions (CatExs); direct data collection efforts; identify project alternatives; and conduct agency and public coordination. and 4. Outside Legal Counsel, 5. Construction Management Firms, 6. Commissioning Agents, 7. Contractors, and 8. Regulatory Agencies. Both development project implementation and water resource issue management have numerous actions that need to be executed. Matching the responsibilities for executing those actions within specific projects to the general project roles and responsibilities of the various stakeholders can be challenging at times. It is not unusual for projects to have gaps, ambiguities, and conflicts in responsibilities and among project roles. As part of the Water Resource Issue Management Plan, it is recommended that a template for typical roles and responsibilities be created for general use on development projects that include water resource issue management. Once planning is initiated for a particular project, the tem- plate can be used as a base from which project-specific roles and responsibilities can be defined. The definition of roles and responsibilities can be supplemented by protocols describing the interactions among the roles, including identification of points of contact, coordination meet- ings, protocols for information exchange, and means for addressing conflicts among stakehold- ers with differing priorities. This process might also benefit by establishing specific environmental and planning goals that are understood by all members of the project team. Worksheet 4 in Appendix A provides an example of how key roles and responsibilities can be documented. 2.3.2 Protocols for Managing the NEPA Process For all airport projects requiring federal approval, meeting the requirements of NEPA are an essential and overarching aspect of the planning process. An overview of the NEPA process is provided in Appendix C. For the purposes of effectively managing water resource issues associ- ated with development project implementation, it is crucial to define how the NEPA process will be executed as part of the Water Resource Issue Management plan. It is recommended that

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42 A Handbook for Addressing Water Resource Issues Affecting Airport Development Planning essential elements of the NEPA process be defined as part of the original Plan development. As individual projects are Key Notes initiated, the plan for that project can be modeled on those The project management team must define--in essential elements and modified as needed for the specific coordination with regulators--when permitting for project. This may improve the consistency of the NEPA individual water resource issues will occur relative process from project to project. to the schedule for the NEPA process. In the context of water resources, the NEPA process This will drive the determination of information includes an environmental review of a project's (or pro- needs and the schedule for development of design gram's) impacts to water resources and an assessment of documents. water resource mitigation, which may, for example, include storm water detention, wetland mitigation banking, and so forth. NEPA evaluation can be based on a less-detailed def- inition of a project than is needed in the permitting process. NEPA approval does not guarantee permitting approval. The NEPA process requires a clear understanding of the elements of a project, the purpose of and need for the project, an assessment of alternatives to the project, and an environmental review of the project's effects on environmental resources--for example, a demonstration that all efforts to avoid and minimize impacts to water resources were considered. In terms of reviewing effects on environmental resources, a demonstration that a project meets all regulatory guidance, stan- dards, and thresholds and the provision of mitigation, if needed, are required under NEPA. Collection of environmental baseline or inventory data is often delayed until the NEPA process is underway. Virtually all development at an airport cannot occur without one or more federal actions, which triggers compliance with the NEPA. That compliance is demonstrated in the form of a CatEx, an EA, or an EIS. In all cases, the objective of the NEPA documentation is to identify whether the project would exert significant adverse effects on the environment and, where appropriate, identify steps necessary to mitigate adverse effects. If a Water Resource Inventory is assembled independently prior to the NEPA process, the scope of work necessary under NEPA can be streamlined because the understanding of the prob- able effect of a project on water resources would be advanced. However, to the degree that FAA participates in the funding of the NEPA process, the early Water Resource Inventory would likely not receive funding unless included in an FAA-funded effort. Refer to Section 2.2.2 for additional information on early planning and Water Resource Inventories. A key decision in the project timeline is whether to conduct permitting of individual water resource issues as part of the NEPA process. For instance, if a Section 404 permit is required, the USACE must also comply with NEPA before the permit can be issued. Often the FAA NEPA docu- ment can be and is used to meet the USACE NEPA needs. A decision by sponsors to include per- mitting in the NEPA process is usually based on the ability to prepare the permits using the level of project definition/design available at that point. FAA will typically only allow sponsors to prepare up to 25% project design before NEPA is complete, so as not to prejudice the project environmen- tal finding/approval. Depending on the water resource issues and their complexity, undertaking per- mitting during the NEPA process can slow the NEPA review, but also can shorten the time after NEPA before the permit is issued. Conversely, separating the processes can speed NEPA and, thus, enable the project to move further into design. However, should notable project changes occur during the remaining design (including permitting), the changes could require the NEPA process to be revisited. Therefore, the project team needs to weigh the risks of the two approaches. In the Water Resource Issue Management Plan, the basic approach to NEPA at the airport should be documented, along with key considerations to decide at the start of the planning process for individual projects.